On 22 December 2025, the UAE Cabinet issued Decision No. (209) of 2025 regarding Exchange of Information upon Request for Tax Purposes. Under this Decision, companies and other entities in the UAE are required to maintain and provide the competent UAE authorities with information that may be requested by foreign tax authorities based on international treaties. The document came into force on 30 January 2026.
- The UAE exchanges tax information upon request under DTAs and the Convention, targeting specific persons or businesses rather than bulk automatic reporting.
- Obligations apply to natural persons, UAE legal entities and arrangements, foreign permanent establishments, and UAE authorities holding their data, which must respond to Ministry of Finance requests.
- Entities must maintain ownership, identity, accounting, asset, and banking records in the UAE for at least five years and are prohibited from concealing or falsifying information.
- Non-compliance triggers escalating administrative fines, possible doubling for repeat offences, and severe regulatory measures such as suspension or cancellation of licences and operations.
Exchange of information upon request
The exchange of tax information upon request is governed by Double Taxation Agreements (DTAs), as well as the Convention on Mutual Administrative Assistance in Tax Matters. The UAE is a signatory to this Convention and has bilateral DTAs with over 100 jurisdictions.
Information is only shared about a specific person or business if a foreign tax authority asks for it. This is different from automatic exchange (CRS), where data on thousands of bank accounts is sent over every year without being asked for.
To meet international obligations, the UAE Cabinet has set rules for how authorities and taxpayers must keep and collect information, along with fines for those who do not comply.
The obligations to retain and disclose information that could potentially be subject to international exchange apply to:
- Natural persons;
- Legal entities registered or licensed to operate in the UAE (including Free Zone companies);
- Legal arrangements (e.g., trusts, joint ventures);
- Permanent establishments of foreign companies in the UAE.
These entities, along with UAE government authorities that hold their data, must provide records and information to the Ministry of Finance whenever they ask for it and within the set deadlines.
What information must be kept?
UAE companies, legal arrangements, foreign branches, and licensed natural persons (sole proprietors) must keep and regularly update:
- Ownership and identity information (includes information and documents verifying the identity of natural persons, legal and beneficial owners, and persons within the ownership chain of a legal entity or arrangement);
- Accounting records (accounting registers, invoices, contracts, correspondence, and other records and documents reflecting financial transactions);
- Information on net assets (including details of movable and immovable property, other assets held, liabilities incurred, revenues, income, and returns);
- Any other information specified by the Minister.
Banks in the UAE are required to maintain and periodically update banking information, including records of the account holder’s legal and beneficial owners, as well as details of all financial transactions conducted through the account.
Rules for keeping information
Information must be retained for a minimum period of 5 years from the end of the financial year to which it relates. Information related to a legal entity or legal arrangement must be kept for at least 5 years from the date it ceases to exist.
Information must be maintained within the UAE and submitted to the regulatory authority upon request, via the methods and within the timeframes established by the Ministry of Finance. It is prohibited to conceal, destroy, or falsify such information.
How information is obtained and exchanged
UAE regulatory authorities (including federal, local, or free zone authorities) request and collect information and documents from entities they regulate as part of their functions.
The Ministry of Finance collects the necessary documentation from the relevant authorities, who are under a legal obligation to comply.
In its capacity as the competent authority for international tax matters, the Ministry subsequently transmits this information to the requesting foreign state’s competent authority.
Information not subject to disclosure
Information protected by attorney-client privilege is exempt from exchange. This includes confidential information provided by a client for the purposes of legal defense, representation in court, arbitration, or mediation, and any related legal advice.
The exchange of information cannot be carried out if it would violate public policy, pose a threat to the security of the UAE, or occur under other circumstances stipulated by international treaty.
Penalties for non-compliance
Companies or other obligated entities may be subject to the following administrative fines (Art. 7 of the Decision):
| Violation | Fine |
|---|---|
|
Failure to maintain information or documents |
20,000 AED (~5,500 USD) |
|
Failure to provide information or documents within the specified period |
20,000 AED (~5,500 USD) |
|
Providing incorrect or inaccurate information |
60,000 AED (~16,300 USD) |
|
Hiding, destroying, or tampering with information |
100,000 AED (~27,200 USD) |
In the event of a repeat violation within 12 months of the previous penalty, the aforementioned fines are doubled.
Beyond financial penalties, the regulatory authority may impose additional sanctions, including the suspension of licenses, registrations, or permits for a period of up to six months, the refusal of renewals, or total cancellation. In practice, these measures can lead to the temporary suspension or permanent termination of a company’s operations.
Key Considerations
Opening a company in the UAE and its subsequent operations require a diligent approach to corporate and financial record-keeping. The regulator may request this documentation at any time for exchange with foreign tax authorities in accordance with international obligations. To avoid fines and the risk of operational suspension, we recommend maintaining accurate records and responding to all regulatory inquiries promptly.
